Submission on the Draft New Zealand Energy Strategy to 2050

Duncan Catanach compiled the NZRCA's submission on the Draft New Zealand Energy Strategy to 2050 aiming to ensure that NZ's energy needs are met without further degradation of the NZ's wild and scenic rivers.

Background to New Zealand Recreational Canoeing Association (NZRCA)

30 March 2007

  1. Formed in 1957, the NZRCA is the national representative organisation of canoe clubs and recreational kayakers throughout New Zealand. The NZRCA is an incorporated society and is affiliated to the NZ Canoe Federation, which is in turn affiliated to the International Canoe Federation. The NZRCA has delegated authority to represent the NZ Canoe Federation on conservation and access issues.
  2. Previously the NZRCA was known as the New Zealand Canoe Association, prior to the creation of the New Zealand Canoe Federation in 1995/1996.
  3. The NZRCA represents both individual members and affiliated member clubs. Currently there are 30 affiliated Clubs with a combined membership of around 2,500 kayakers plus another 65 individual members. The figure of 2,565 in no way adequately represents the sum total of kayakers in New Zealand, as there are many who do not belong to clubs, and who have not joined the NZRCA as individuals.
  4. The RMA explicitly recognises recreational amenity, and the decisions of Special Tribunals and the Environment Court confirm that whitewater kayaking is of worthy interest in resource management issues. Consequently, the NZRCA has had involvement in numerous resource consents for energy projects including presenting evidence to the Environment Court (although our preference is to settle out of court where possible e.g., MRP - Waikato and Contact - Clutha). We have exercised our role responsibly by giving quality evidence and only contesting relevant and important issues.
  5. Summary of Submission

    There is a risk that strict adherence to the central tenet of the Energy Strategy (that for the foreseeable future all new energy generation be renewable) may result in unacceptable pressures on our remaining free flowing rivers and a high risk of suboptimal environmental and economic outcomes. In particular, hydro power schemes cause significant and in many cases irreversible environmental damage to river environments (i.e., rivers are a non-renewable resource) and this needs to be explicitly recognised in deciding the appropriate mix of energy sources.
  6. The NZRCA will strongly oppose any changes (including any guidance contained in National Policy Statements or National Environmental Standards) that compromises the fundamental tenets of the RMA - sustainable management of our resources (i.e., environmental integrity including the recognition of recreational and amenity value) and a fair and accessible process.
  7. The NZRCA would strongly support any increase in Government support to energy efficiency measures and the development of alternative energy sources. Both of these initiatives would reduce the pressure on our already scarce water resources.
  8. Detailed Submission

    The significant and potentially irreversible environmental costs of hydro power are a strong consideration in deciding the appropriate mix of energy sources.

    New Zealand relies more on hydro-generated electricity than virtually any other country in the world i.e., the environmental and social cost of hydro power has already been very high particularly for whitewater kayakers and other enthusiasts who value natural river environments very highly.

  9. There is a risk that strict adherence to the central tenet of the Energy Strategy (that for the foreseeable future all new energy generation be renewable) may result in unacceptable pressures on our remaining free flowing rivers and a high risk of suboptimal environmental and economic outcomes.
  10. Unlike some other "renewable" energy sources, the environmental damage caused by a hydro scheme is significant and in many cases irreversible. For instance a wind turbine can be dismantled and the natural environment can be relatively easily and quickly restored. However, international evidence suggests that even when hydro schemes are decommissioned river environments are not always easily, quickly or cheaply restored to its natural state i.e., rivers are a non-renewable resource and the classification of hydro as a "renewable" energy source is a misnomer.
  11. These significant and potentially irreversible effects need to be taken into account when making decisions on the optimal mix of energy sources. For instance, one would hope that in the future other more environmentally-friendly energy sources will become economically viable. It makes sense then, to give priority to energy sources that have fewest long-lasting or irreversible environmental effects. In short, we have a choice between changing to alternative (i.e., non-hydro) sources of energy in the near future, when there are many fine rivers still left; or changing over later when many of those same fine rivers will be lost.
  12. Table 4.1 (p 51) suggests that there is an additional 5,800 GWh of hydro power available. This analysis is based purely on one economic criterion, the price of generation. We would suggest that hydro availability may be considerably lower if proper consideration is given to environmental and social costs and that alternative energy sources and greater energy efficiencies need to be sought.
  13. If significant hydro generation is necessary, consideration should be given to multi-lateral consultation at a national level between generators, Government and affected parties so that options to minimise the long term environmental and social impacts of hydro power are thoroughly explored.
  14. We oppose any changes to the RMA that compromise the fundamental tenets of environmental integrity via a fair and accessible process.

    The Strategy signals that changes will be made to the RMA to effect the provision of "leadership and guidance for the consenting of renewable electricity generation" (p. 15). We understand that these changes are likely to include the development of a National Policy Statement (NPS) around renewable energy generation.

  15. The NZRCA will strongly oppose any changes to the RMA that compromise the fundamental tenets of the RMA:
    • Sustainable management of our resources including the recognition of recreational and amenity value i.e., environmental integrity, via
    • A fair and accessible process - any change that would limit the ability of community organisations such as the NZRCA to participate in the decision-making process would be strongly opposed.
  16. We have a concern that in implementing the Draft Energy Strategy there is a risk that the central tenets of the RMA outlined in the previous paragraph (environmental integrity and a fair and accessible process) will be compromised. For instance, we understand that there will be an assumption that renewable energy projects, including hydro power is a "nationally significant activity". A blanket application of this approach is likely to be inconsistent with the Sustainable Water Programme of Action i.e., water bodies may be nationally significant for recreation as well as hydro power and this needs to be explicitly recognised.
  17. We also understand that the NPS is likely to require decision-making bodies to explicitly recognise the social and economic benefits of hydro and other renewable energy forms. We would argue that there are also significant social and economic costs attached to hydro power schemes that are not necessarily fully recognised in current decision-making processes e.g.,
    • The cost of decommissioning hydro schemes including adequate environmental restoration is often an unaccounted liability and this may preclude appropriate decommissioning in the future e.g., when more environmentally and socially friendly technologies become economically viable and/or hydro schemes come to the end of their natural life (e.g., excess siltation and/or eutrophication of the reservoir).
    • The option value foregone (i.e., the hydro scheme limits future options for the use of resource) is rarely accounted for in decision-making processes. Societal values (including recreational) and technology can change significantly even during the lifetime of a hydro scheme (let alone in perpetuity) indicating that the option value foregone can be large.

    Additionally as further river environments are destroyed by hydro and irrigation schemes, it is likely that the value society places on remaining natural river environments will increase.

  18. Energy efficiency and the development of more environmentally friendly alternative energy sources should be strongly promoted.

    The NZRCA supports the measures proposed in the Draft Energy Strategy (and would welcome additional measures) that are aimed at increasing energy efficiency, reducing energy consumption (e.g., the provision of better public transport) and developing alternative energy sources as this will reduce the pressure on our scarce water resources.

  19. There is a prima facie case of market failure in the electricity market. Post-deregulation there are few economic incentives to promote and seek demand-side energy efficiencies - revenue growth is generally only associated with increased generation. In other words, there is a clear role for the Government to intervene.
  20. The economic case for intervention is also strong:
    • By the Draft Energy Strategy's own calculations the cost per KWh of energy saved (< 4c per KWh) due to energy efficiency promotion is considerably less than the cost of generation used to generated Table 4.1 (9c per KWh).
    • In a recent article in the Dominion Post (8 Mar 07), Mike Underhill, Chief Executive of Wel Networks, argued that "we spend $9 billion annually on energy and waste $7 billion of it... if New Zealand had spent as much on energy efficiency as it had on economic reform in the energy sector [$1.5 billion] the country would be better off".
  21. The NZRCA believes that the Government needs to put far greater emphasis on energy efficiency. For instance, it has been estimated (Dominion Post, 8/3/07) that the equivalent of six years' future demand for growth could be saved through simple measures such as energy-saver bulbs, solar heating and insulation. This alone would significantly reduce the pressure on one of our scarcest resources - free flowing, natural river environments and the recreational amenity they provide.

Duncan Catanach
North Island Conservation Officer
New Zealand Recreational Canoeing Association